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Targeted brownfield assessment for Oklahoma Army National Guard former Stilwell armory, Stilwell, Oklahoma

TARGETED BROWNFIELD ASSESSMENT
For
Oklahoma Army National Guard
Former Stilwell Armory
Stilwell, Oklahoma
ASTM E 1527-05
Phase I Environmental Site Assessment
All Appropriate Inquiry
Prepared by:
April 19, 2013
Phase I TBA 2 Former Stilwell Armory
Stilwell, Oklahoma
Table of Contents
1.0 Executive Summary……………………………………………………………………………………………………..…………….…………………….. 4
2.0 Introduction………………………………………………………………………………………………………………..…………….………………..….. 6
2.1 Purpose …………………………………………………………………………………………….……..…………………………..…………………… 6
2.2 Detailed Scope-of-services ……………………………………………………………….…………………………………..…………………… 6
2.3 Significant Assumptions …………………………………………………………………….…………………..…………..…………………….. 6
2.4 Limitations and Exceptions ………………………………………………………………………….……………………..…………………….. 7
2.5 Special Terms and Conditions ………………………………………………………………………………..………………………………….. 7
3.0 Site Characterization and History ………………………………………………………………………………………………….…………..…… 8
3.1 Location and Legal Description ………………………………………………………………………………………………………………….. 8
3.2 Site and Vicinity Characterization …………………………………………………………………………..……………………………..….. 8
3.3 Descriptions of Structures, Roads and Other Improvements ………………………………..……………………………….……. 9
3.4 Owner, Property Manager, and Occupant Information ………………………………………………………………..…………….… 9
3.5 Information Reported by User Regarding Environmental Lien or Specialized Knowledge or Experience ….…….. 9
3.6 Commonly Known or Reasonable Ascertainable Information ………………………….…….…………………..……………….. 9
3.7 Valuation Reduction for Environmental Issues ……………………………………………………….………………………………….. 10
3.8 Current Use of Property …………………………………………………………………………………………………..……………………….. 10
3.9 Past Use of Property ………………………………………………………………………………………………………………………..……….. 10
3.9.1 Review of Aerial Photos …………………………………………………………………………………..………………………………. 10
3.9.2 Fire Insurance Maps ………………………………………………………………………………………………………………..……….. 11
3.10 Current and Past Use of Adjoining Properties ………………………………………………….…….………………………………….. 11
3.11 Environmental (Physical) Setting ……………………………….……………………..………………………………………………..…….. 11
3.11.1 Surface Water Characteristics ……………………………………………………………………….…………………………..…….. 11
3.11.2 Subsurface Geological Characteristics …………………………..………………………….…….………..……………….…….. 12
3.11.3 Ground Water Characteristics ……………………………………………………………………….……………………..………….. 12
3.11.4 Air Characteristics ……………………………………………………………………………………………………………….………….. 13
4.0 Records Review ………………………………………………………………………………………….……………….………………………..……….. 14
4.1 Federal National Priorities List (NPL) ……………………………………………………………………..………………………...……….. 14
4.2 Federal CERCLIS List ……………………………………………………………………………………………….……………………………….. 14
4.3 Federal RCRA CORRACTs List ………………………………………………………………………….…..……………………………..…….. 14
4.4 Federal RCRA non-CORRACTS TSD List …………………………………………………….………………………………………….…….. 14
4.5 Federal RCRA Generators List ……………………………………………………………………………………...………………………….. 15
4.6 Federal ERNS List …………………………………………………………………………………………………………………………………….. 15
4.7 Federal Institutional Control/Engineering Control Registries …………………………………………..………………..……….. 15
4.8 State-Equivalent NPL ………………………………………………………………………………………….……..………………..………….. 15
4.9 State-Equivalent CERCLIS ………………………………………………………………………………..……………………………..……….. 15
4.10 State Landfill and/or Solid Waste Disposal Sites ……………………………………………………..……………………..………….. 15
4.11 State Leaking UST List ………………………………………………………………………………………….…………………………..……….. 16
4.12 State Registered UST Sites ……………………………………………………………………………………….……………………………….. 16
4.13 State Institutional Control/Engineering Control Registries …………………………………….……..………………..………….. 16
4.14 State Voluntary Cleanup Sites ………………………………………………………………………….……….…………………..………….. 17
4.15 State Brownfield Sites ……………………………………………………………………………………..……….…………………..………….. 17
4.16 Oil and Gas Records …………………………………………………………………………………………….……….…………………..………….. 17
4.17 Dry Cleaner Databases ………………………..………………………..………………………..…………………………………....………… 17
5.0 Site Reconnaissance and Interviews ……………………………………………………………………..……….……………….…………….. 18
5.1 Methodology and Limiting Conditions ……………………………………….……………………………..……………………………….. 18
5.2 General Site Conditions ……………………………………………………………….…………………………………………………..……….. 18
5.2.1 Above Ground Storage Tanks (ASTs) …………………………………………………………..……………………………..………. 18
5.2.2 Landfills and/or Dumping …………………….…………………………………………………………….………………………..……. 18
5.2.3 Impoundments ……………………………..…………………………………………………………………..………………….……….. 18
Phase I TBA 3 Former Stilwell Armory
Stilwell, Oklahoma
5.2.4 Monitoring Wells ……………………………………………………………………………………………..……………………………… 19
5.2.5 Disturbed and Stained Soil ……………………………………………………………………………….……………….……………… 19
5.2.6 Seeps …………………………………………………………………………………………………………….………………….…………….. 19
5.2.7 Chemical Spills …………………………….………………………………………………………………..………………….…………….. 19
5.2.8 Farm Waste ……………………………………………………………………………………………………………………..……………….. 19
5.2.9 Known Pesticide Misapplication ………………………………………………………………………………………….…………….. 19
5.2.10 Discharges and Runoff from Adjacent Property Affecting the Site ………………………………..…………….……….. 19
5.2.11 Petroleum Products and Oil and Natural Gas Exploration ……………………………………..…..……………..……….. 20
5.2.12 Asbestos ………………………………………………………………………………………………………………………………………….. 20
5.2.13 Lead ……………………………………………………………………………………………………………………..……………….………….. 20
5.2.14 Transformers/PCB Equipment ………………………………………………………………………..…….……………….………….. 20
5.3 External Observations …………………………………………………………….………………………………..…..………………………….. 20
5.4 Internal Observations ………………………..…………………………………………………………………….……..……………………….. 21
5.5 Interviews ……………………………………………………………………………………………….…………………………………..………….. 21
6.0 Findings ……………………………………………………………………………………………………………………….……………………..………….. 22
7.0 Opinion and Recommendations …………………………………………………………………………………..……………………..………….. 23
8.0 Data Gaps …………………………………………………………………………………………………………………………………………..………….. 23
9.0 Conclusions ………………………………………………………………………………………………………………….…………………..…………….. 23
10.0 Additional Services ……………………………………………………………………………………………………………………………..………….. 23
11.0 Deviations …………………………………………………………………………………………………………………………………………..………….. 23
12.0 References …………………………………………………………………………………………………………………….………………………..……… 24
Appendices
A. Qualifications of Environmental Professionals
B. Photographs from site visit/Site notes
C. Aerial Photographs
D. FEMA Flood Zone Map
E. Sanborn Map
F. USGS Topographical Map / Site Maps
G. Deeds
H. ERNS Records for Stilwell, OK
J. RCRA Records for Stilwell, OK
K. Underground Storage Tank Removal Documents
L. Oklahoma Corporation Commission UST records
M. Oklahoma Water Resource Board Water Wells
N. Air Quality Permitted Facilities
O. Memorandum of Agreement between Oklahoma Department of Environmental Quality and the City of
Stilwell
P. Oklahoma Military Department Environmental Office Records for Madill Armory, 421 W. Pine St., Stilwell,
OK.
Q. Site Cleanup Assistance Program Lead Based Paint and Asbestos Inspection Documents
Background and Disclaimer
Phase I TBA 4 Former Stilwell Armory
Stilwell, Oklahoma
1.0 Executive Summary
On May 3, 2012, Rachel Francks and Franziska Landes of the Oklahoma Department of
Environmental Quality (DEQ) performed site reconnaissance of the former Stilwell National Guard
Armory located at 421 West Pine St., Stilwell, Adair County, Oklahoma, as part of a Targeted
Brownfield Assessment (TBA). The subject property is situated on the southern side of the City of
Stilwell and is part of a school complex that includes sports fields and is used by the City of Stilwell
as a meeting and activity center. The purpose of the TBA was to identify potential environmental
concerns by reviewing historical data, regulatory information, and by performing a visual inspection
of the site and surrounding area. The following is an executive summary of the environmental site
assessment results:
 Recognized environmental conditions (REC) include insulation around pipes that are asbestos
containing materials (ACMs), lead-based paint (LBP), and lead dust from firearms and from
degrading LBP.
 Four historic dry cleaners were found within a half mile of the site. One currently operating dry
cleaner was found within a mile of the site. It is unknown whether the dry cleaners are
upgradient of the site but it is possible based on surface topography.
 The former Stilwell National Guard Armory was built in 1954. The property was managed and
maintained by the Oklahoma Military Department (OMD) on behalf of the State of Oklahoma.
Ownership of the subject property has been transferred to the City of Stilwell as of June 15,
2011. The City of Stilwell is currently working on clean up and development of the site for use
by the City of Stilwell as a community center and the Veterans of Foreign Wars (VFW) as a
museum. Building repair has begun and once cleanup activities have occurred, the City of
Stilwell will begin occupying the building.
 There is one large building on the site. The offices and class rooms surround the motor pool
maintenance area and the drill floor. All equipment has been removed, with the exception of a
stove, heating and cooling units and the water heater. There are pipes in the latrines and the
janitor’s closet to the east of the drill floor that are surrounded by insulation that has been
confirmed as ACM. The pipes extend along a wall around the drill floor to the motor pool on the
west side of the building. The asbestos pipe wrap appeared to be in good condition.
 Adjoining properties consist of the sports fields, and residential area. Historical aerial
photographs beginning in 1939 show the subject property as fair grounds and residential. Aerial
photos from 1995 – 2010 show the area around the location to be occupied by the sports fields
and residential housing.
 The property is located centrally within Stilwell, and Sanborn Fire Insurance maps show the
subject property to contain a fair building and a park on a neighboring property. The fire
insurance maps show the surrounding areas to be residential.
 No National Priority List (NPL), delisted NPL sites, Resource Conservation and Recovery Act
(RCRA) non-corrective action sites (CORRACTS) treatment, storage, and disposal (TSD) listings,
Emergency Response Notification System (ERNS) list, Institutional Controls/Engineering
Phase I TBA 5 Former Stilwell Armory
Stilwell, Oklahoma
Controls, or State landfills and/or solid waste disposal sites were found on the subject property
or within the ASTM recommended search radii. No RCRA generators, Voluntary Cleanup (VCP)
sites, or Brownfield sites were found on the subject property. There were no archived
Comprehensive Environmental Response, Compensation, and Liability Information System
(CERCLIS) site listings within a ½ mile of the subject property.
 There was one underground storage tank (UST) on site. It had a 1,000 gallon capacity and was
used to store gasoline. The tank was closed in 1978 and removed in 1995 and the case was
closed by the Oklahoma Corporation Commission (OCC). At the time of removal, the soil below
the tank and to the side was tested for total petroleum hydrocarbons (TPH). The results showed
all tested contaminants to be below detection limits. When pulled the tank was in good
condition with no holes. The tank pit was filled with clean soil. During the site visit on May 3,
2012, there was no sign of the UST or soil staining and the pump island had been removed as
well. The UST is considered a historical recognized environmental condition (HREC).
 OCC Oil and gas exploration records were searched for wells on the subject property and
adjoining properties. There was no record of oil and gas production on the subject property or
any adjoining sites.
 Transformers were noted to the north, east, and south of the armory. They are off the property
and it is unknown if they contain polychlorinated biphenyls (PCBs), but the units appear new
and in good condition. Fluorescent lighting ballasts are located throughout the offices in the
building. The lighting ballasts are all in good condition in most rooms. The lights in the drill floor
and the garage are old incandescent bulbs and new fluorescent installations. All fluorescent
bulbs contain mercury and should be handled as Universal Waste unless documentation and/or
sampling demonstrate they are not hazardous.
 Four LUSTs were found within a half mile of the subject property. It is unknown whether the
LUSTs are upgradient of the site but it is possible based on surface topography.
Phase I TBA 6 Former Stilwell Armory
Stilwell, Oklahoma
2.0 Introduction
The State of Oklahoma Department of Environmental Quality (DEQ) under a Brownfield Assistance
Agreement (No. RP96681001-0) (Ref. 1) with the U.S. Environmental Protection Agency (EPA)
conducted a Targeted Brownfield Assessment of a property located at 421 West Pine St., Stilwell,
Adair County, Oklahoma.
2.1 Purpose
The purpose of this assessment is to look at the environmental conditions within the target
area and provide this information to the City of Stilwell as well as meet the All Appropriate
Inquiry requirement of the landowner liability protections under the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA, better known as
Superfund – Ref. 2), as provided in the Small Business Relief and Brownfield’s Revitalization
Act of 2002 (Public Law 107-118, Subtitle B – Ref. 3). The purpose of a Phase I
Environmental Site Assessment is to identify, to the extent feasible, recognized
environmental conditions in connection with the target property through a systematic
review of readily available information sources and a site reconnaissance.
DEQ is providing technical assistance to the project by evaluating the environmental
condition of the property prior to the City of Stilwell converting the armory for use as a
community center and by the VFW as a museum. Funding for this assessment has been
provided by the U.S. Environmental Protection Agency (EPA).
2.2 Detailed Scope of Services
DEQ examined the current use of the property and identified the historical uses of the
property to determine if recognized environmental conditions exist. DEQ examined
historical documents, governmental databases, oil and gas records, aerial photographs,
Sanborn Fire Insurance Maps, and conducted interviews and a site reconnaissance of the
area. A good faith effort was made to identify possible environmental conditions that might
affect the development of the property.
2.3 Significant Assumptions
History and knowledge of the subject property shows that the building was used as a
National Guard Armory. Prior to armory construction in 1954, the property was used as a
County Fairgrounds. There has been no oil and gas exploration on the property according to
OCC records.
Since the building was constructed in 1954, the building may contain ACM. The U.S. began
banning the use of asbestos in most building materials in the 1970s due to studies
confirming the harmful health effects caused by exposure to airborne asbestos. Insulation
Phase I TBA 7 Former Stilwell Armory
Stilwell, Oklahoma
observed in the building during the site reconnaissance conducted on May 3, 2012, has been
confirmed to contain asbestos. DEQ’s contractors performed a lead and asbestos survey on
the property. Lead-based paint, lead dust, and asbestos containing materials were found in
the building. See Sections 5.2.12 and 5.2.13 for more information on asbestos and lead
found in the building.
2.4 Limitations and Exceptions
The purpose of an environmental site assessment is to identify actual or potential
“recognized environmental conditions” that may result in liability, land use restrictions, or
cause delays in revitalization. The ASTM Phase I Environmental Site Assessment E 1527 – 05
(Ref. 4) is the minimum standard for environmental due diligence in the real estate industry
and meets the standard for All Appropriate Inquiry under the Small Business Liability Relief
and Brownfields Revitalization Act of 2002. A diligent effort in accordance with generally
accepted good commercial and customary standards and practices was undertaken to
identify the “recognized environmental conditions” that might affect the revitalization
project. However, the identification of old hazardous waste sites is an evolving process;
therefore, DEQ cannot state with absolute certainty that no other potential hazardous
waste sites are located in the area. This assessment was conducted under constraints of
time, cost, and scope and reflects a limited investigation and evaluation. It reflects the
normal degree of care and skill that is ordinarily exercised by environmental professionals
conducting business in this or similar localities. In no event shall the DEQ or its employees
be liable for any damages, injury, loss, cost or expense whatsoever arising in connection
with the use or reliance on the information contained in this report, except as otherwise
provided by law.
The information in this report is based on a review of governmental records, interviews with
knowledgeable representatives of the property, information provided by the City of Stilwell,
and observations of the environmental professional. The result of this assessment, as
written in this report, is valid as of the date of report. The assessment does not include
sampling of rock, groundwater, surface water, or air. For qualifications of environmental
professionals see Appendix A.
2.5 Special Terms and Conditions
This assessment report has been prepared for the City of Stilwell by the DEQ using EPA
funding. Information about this report will be provided to the EPA for its files. This report
and the working file are public record and subject to the Oklahoma Open Records Act and
the federal Freedom of Information Act.
Phase I TBA 8 Former Stilwell Armory
Stilwell, Oklahoma
3.0 Site Characterization and History
3.1 Location and Legal Description
The subject property is located at 421 West Pine St. in Stilwell, Oklahoma. This property
consists of approximately two and a half acres of land and contains the former National
Guard Armory building. A site map and topographical map depicting the property have
been provided in Appendix F.
The subject property is located in NE ¼ SE ¼ of Section 34, T16N, R25E, Adair County,
Oklahoma. The armory building’s legal description is:
The West half of Lot 2, and all of Lots 3 and 4 and the West half of Lot 5 of Block 17, and the
West 150 feet of an alley way 20 feet wide extending East and West within Block 17, and a tract
of land described as follows: Beginning at the Northwest comer of Lot 3 in Block 17 of the
original town of Stilwell, Oklahoma; thence running in a Southerly direction along the West line
of said Block 17, a distance of 300 feet to the North line of Pine Street; thence in a Westerly
direction along the North line of Pine Street extended, a distance of 60 feet; thence in a
Northeasterly direction parallel with the West line of said Block 17, a distance of 300 feet the
South line of Popular Street; thence in an Easterly direction 60 feet to place of beginning, all in the
original Town of Stilwell, Oklahoma, according to the U.S. Government Survey thereof.
3.2 Site and Vicinity Characterization
The former Stilwell Armory was built in 1954. According to Adair County land records, the
land for the building was owned by the City of Stilwell and was deeded to the State of
Oklahoma for the construction of the Oklahoma National Guard Armory on September 10,
1954 (see Appendix G). The subject property is a tract of land about 1.1 acres in size, and is
located at 412 West Pine Street, Stilwell, Oklahoma. It is bounded by Poplar St. on the
north, 5th Ave on the west, and Pine St on the south. The areas where the subject property
and adjacent properties are located are best characterized by residential development.
Residences surround the subject property to the north, east and south, and a sports field is
to the west.
Asbestos and LBP have been confirmed in the building by DEQ contractors. Utilities that
serve the subject property are the City of Stilwell for electricity, North East Oklahoma Public
Facilities Authority (NEOPFA) for gas service, and the City of Stilwell provides water and
sewer services to the armory according to Ronnie Trentham (Mayor of the City of Stillwell).
A review of the topographical map indicated that the surface elevation of the site is
approximately 340 feet above mean sea level. The topographical gradient is to the
northwest, toward Caney Creek. Caney Creek is located approximately 0.4 miles from the
site to the west. The topographical map can be found in Appendix F.
Phase I TBA 9 Former Stilwell Armory
Stilwell, Oklahoma
3.3 Description of Structures, Roads, and Other Improvements
The structure of the armory is in good condition. The floor was in good condition, though
there are cracks in some of the tiles and paint is present below the tiles. Yellow mastic was
noted under damaged tiles. Windows were in good condition at the Armory and are not
original to the building and were recently replaced according to Ronnie Trentham. Roads
surrounding the Armory and the front parking lot are in good condition. The rear parking
area is surrounded by chain link fence and is covered in grass. The only area of stressed
vegetation seemed to be associated with the increased traffic from the renovation being
performed on the building. Adjacent properties, which consist of residential and sports
fields, are in good condition. Throughout the facility, there are floor drains. Based on
previous armories, it is thought that these drains lead into the city sanitary sewage pipes,
but at the time of this report that could not be confirmed.
3.4 Owner, Property Manager, and Occupant Information
The subject property is owned by the City of Stilwell and is currently occupied by groups
using the building for sports classes and events, at the time of the inspection the armory
was undergoing renovation. Large pallets of supplies were stacked around the outside of
the building and in some areas of the drill floor. DEQ Site Cleanup Assistance Program
(SCAP) is in charge of identifying environmental hazards and conducting the cleanup of
asbestos and lead in the Armory. The Military department transferred ownership of the
armory to the City of Stilwell prior to completion of remedial activities (Appendix O).
3.5 Information Reported by User Regarding Environmental Lien or Specialized Knowledge or
Experience
The property owner and/or representatives reported no environmental liens on the subject
property, and had no specialized knowledge or experience regarding recognized
environmental conditions. The DEQ conducted a search for environmental liens at the Adair
County Courthouse. No environmental liens or use limitations were reported for the subject
property, and it does not appear in the Brownfield IC database.
3.6 Commonly Known or Reasonably Ascertainable Information
Ronnie Trentham, Stilwell City Mayor, indicated that to the best of his knowledge the land
had been owned only by the City of Stilwell who then provided the land for construction of
the armory. It is known within the community that the building functioned as a National
Guard Armory.
Phase I TBA 10 Former Stilwell Armory
Stilwell, Oklahoma
3.7 Valuation Reduction for Environmental Issues
Valuation of the property is outside the scope of this assessment. A professional appraiser
should be consulted to place a value on the property.
3.8 Current Use of the Property
The property is currently being used as a community center and area for sports classes and
events by the City of Stilwell. Renovation is currently underway on the property.
3.9 Past Use of the Property
3.9.1 Review of Aerial Photographs
Historic aerial photographs were searched to view the changes to the property
over time. The 1939 aerial photograph was found at the Oklahoma Department
of Libraries. The aerial photographs from 1995, 2003, 2005, and 2012 were
found on Google Earth. Aerial photographs from 1939, 1995, 2003, 2005, and
2012 were obtained. All aerial photographs are located in Appendix C. The
following represents a summary of what was found at the subject property from
each photograph.
1939 aerial photograph
The 1939 aerial photograph shows the subject property to be fair grounds with
park land to the west. There is residential property to the north, east and south
of the property. There is one structure visible on the subject property, which
are most likely the fairgrounds buildings.
1995 aerial photograph
The 1995 aerial photograph shows the subject property with the Armory. There
is a sports field to the west of the subject property. The property is largely
surrounded by residential areas to the north, east and south.
2003 aerial photograph
The 2003 aerial photograph shows the subject property with the Armory. There
is a sports field to the west of the subject property. The property is largely
surrounded by residential areas to the north, east and south.
Phase I TBA 11 Former Stilwell Armory
Stilwell, Oklahoma
2005 aerial photograph
The 2005 aerial photograph shows the subject property with the Armory. There
is a sports field to the west of the subject property. The property is largely
surrounded by residential areas to the north, east and south.
2012 aerial photograph
The 2005 aerial photograph shows the subject property with the Armory. There
is a sports field to the west of the subject property. The property is largely
surrounded by residential areas to the north, east and south.
3.9.2 Fire Insurance Maps
The 1925 Sanborn maps show the area occupied by fairground buildings. The
areas to the east, south and north appear to be occupied by residential
structures. The area to the west isn’t shown on the smaller maps, but on the
key sheet the area appears as a park.
3.10 Current and Past Uses of Adjoining Properties
Currently the areas surrounding the site are residential and sports fields. The areas to the
north, east and south have always been residential and are still residential. The area to the
west has historically been a park and is currently occupied by a sports field.
3.11 Environmental (Physical) Setting
DEQ reviewed several sources to obtain information on the physical setting of the subject
property and its surrounding areas. These sources include: The United States Department
of Agriculture Adair County Soil Survey, Oklahoma Water Resource Board data viewer, and
the Federal Emergency Management Association. Review of the physical setting of the area
is to evaluate the sensitivity of the hydrogeology to potential contamination from sources
either on or near the site.
3.11.1 Surface Water Characteristics
The topography of the area is relatively flat. The former Stilwell Armory is located at
a surface elevation of approximately 350 feet above mean sea level. The
topographical gradient is to the west, toward Caney Creek. Caney Creek is located
approximately 0.4 miles southwest of the site.
Phase I TBA 12 Former Stilwell Armory
Stilwell, Oklahoma
According to the Federal Emergency Management Association (FEMA), the subject
property is in an area outside the 500 year flood plain A map of this information is
located in Appendix D.
3.11.2 Subsurface Geological Characterization
Adair County is mainly comprised of the Boston Mountains and the Ozark Plateau
within the Ozark Uplift regions. This area is characterized by a deeply dissected
plateau formed by limestones and cherts, and capped in places by Pennsylvanian
sandstones. Caves and sinkholes may occur in this area (Ref. 19).
According to the Soil Survey of Adair County, Oklahoma, the subject property
consists of Apperson silty clay loam. Apperson silty clay loam comprises 100% of
the subject property area of interest and is characterized by a slope of 0 to 1
percent, a water table depth of over 18 to 24 inches, and high water capacity (Ref.
14).
3.11.3 Ground Water Characteristics
The hydrogeology as reported by the Oklahoma Water Resources Board (OWRB)
indicates the site is on the Boone which is a minor groundwater basin, and the
Rubidoux which is a major groundwater basin. The Boone basin is unfavorable for
production of groundwater due to its low yield of 10 gpm. The Rubidoux basin is a
bedrock basin with a strongly varying saturated thickness. The Rubidoux is generally
unfavorable for groundwater production due to high chloride levels in the water.
The aquifer vulnerability for the area around the site is high for the Boone Basin and
low for the Rubidoux.
The OWRB Reported Well Log Viewer was utilized to make a map of groundwater
and monitoring wells within a half mile radius of the subject property. There are a
number of wells within 0.50 miles of the property, mostly used for site assessment
and water monitoring purposes. The closest groundwater well is 0.2 miles south of
the subject property, and is used for domestic water purposes. For a list and map of
wells that are within 0.50 miles of the subject property, see Appendix M.
The subject property obtains its drinking water from the City of Stilwell Utilities,
which uses surface water as its water source. The City of Stilwell is currently using
Stilwell City Lake, to the southwest of the city, as its water source.
3.11.4 Air Characteristics
No air emissions were noticed at the subject property or the adjoining properties.
The DEQ dataviewer database was searched for Air Quality Permitted Facilities
Phase I TBA 13 Former Stilwell Armory
Stilwell, Oklahoma
(AQPF). No AQPF were found within a 1 mile radius from the subject property.
There is a potential for lead dust and asbestos emissions from the subject property.
Phase I TBA 14 Former Stilwell Armory
Stilwell, Oklahoma
4.0 Records Review
A regulatory database search was conducted by DEQ. This search included, at a minimum, those
records and distances from the site dictated as appropriate in the ASTM standard. DEQ performed a
review of available federal and state databases to assess whether the subject property or proximate
properties were listed as having environmental concerns, which could have an adverse impact on
the subject property. The following provides a summary of the databases reviewed.
4.1 Federal National Priorities List (NPL)
A search of the Environmental Protection Agency’s NPL database shows no current NPL sites
within a mile radius of the subject property (Ref. 5). The subject property is not an NPL site.
The database also shows no delisted NPL sites within a half mile radius of the subject
property.
4.2 Federal CERCLIS List
The EPA database for Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) Information Systems (CERCLIS) was searched for active and archived CERCLIS
sites on and near the subject property (Ref. 7). The ASTM’s recommended search radius for
the subject property for both active and archived CERCLIS sites is ½ mile. No CERCLIS sites
were found within a ½ mile radius of the site. The property is not listed as an active CERCLIS
site.
The subject property is also not listed in the archived CERCLIS site list. There are no archived
sites within a ½ mile of the subject property.
4.3 Federal RCRA CORRACTs List
The EPA database for Resource Conservation and Recovery Act (RCRA) facilities subject to
corrective action was searched within the ASTM’s required minimum distance of one mile of
the subject property (Ref. 8). No RCRA CORRACT facility was found within the one-mile
radius of the subject property.
4.4 Federal RCRA non-CORRACTS TSD List
The EPA database for RCRA facilities not subject to corrective action was searched within
the ASTM’s required minimum distance of ½ mile of the subject property (Ref. 8). No RCRA
non-CORRACT Treatment, Storage and Disposal (TSD) sites are within the ½ mile radius of
the subject property.
Phase I TBA 15 Former Stilwell Armory
Stilwell, Oklahoma
4.5 Federal RCRA Generators List
The EPA RCRA Notifiers database was searched for RCRA generators within the ASTM’s
required minimum search distance of the subject property and adjoining properties (Ref. 8).
The subject property did not have any RCRA notifiers or generators. There were also no
facilities found near the subject property. No large quantity generators were reported
within the subject property and its adjoining properties. For a list of local generators
outside of the search radius see Appendix (J).
4.6 Federal ERNS List
The Emergency Response Notification system (ERNS) maintained by the National Response
Center was searched for any hazardous substance releases or spills within the subject
property (Ref. 9). ASTM requires a minimum search distance of property only when
identifying ERNS cases. No ERNS sites were reported within the property or the adjoining
properties. For a list of local incidents outside of the search radius see Appendix (H).
4.7 Federal Institutional Control/Engineering Control Registries
Federal institutional control/engineering control registries are still under development.
There are no known Institutional Control/Engineering Controls in effect for this property.
Following cleanup of asbestos and lead, the DEQ Site Cleanup Assistance Program will file a
deed notice on the property.
4.8 State-Equivalent NPL
DEQ does not have a State-equivalent NPL database. Oklahoma does not have a State
Superfund law to establish a State-equivalent NPL database.
4.9 State-Equivalent CERCLIS
DEQ does not have a State-equivalent CERCLIS database.
4.10 State Landfill and / or Solid Waste Disposal Sites
DEQ regulates landfills and solid waste disposal sites across the State of Oklahoma (Ref. 10).
State landfills and solid waste disposal facilities were searched in the DEQ database within
the ASTM required minimum distance of ½ mile from the subject property. No permitted
landfills or solid waste disposal facilities are located within the search distance of the subject
property.
Phase I TBA 16 Former Stilwell Armory
Stilwell, Oklahoma
4.11 State Leaking UST List
The OCC UST Notification Database and OWRB’s Online Data viewer were searched to locate
any known leaking underground storage tank (LUST) sites located within the ASTM’s
minimum search distance of a ½ mile of the subject property. Four LUST sites were found
within the ½ mile radius. The following sites are listed and described below.
 Ez Mart #550, located at 110 North 2nd St., is south east of the subject property. The
three of the tanks are listed as permanently out of service, two of the tanks are listed as
currently in service, and the cases are all closed, but there are no other records
regarding these LUSTs. The LUST case Facility ID number is 064-1952.
 Harvest Foods, located at 419 North 2nd St., is north east of the subject property. The
two tanks are listed as permanently out of service and backfilled. The cases are closed.
The LUST case Facility ID number is BF-0215.
 Olives Station, located at North 2nd St. and Hwy 59, is northeast of the subject property.
The tanks are listed as permanently out of service and the cases are closed. The LUST
case ID number is 064-2284.
 Stilwell Foods, located at 5 East Walnut St., is south east of the subject property. The
tanks are listed as permanently out of service and the case is closed. The LUST case
Facility ID number is 064-PN.
4.12 State Registered UST Sites
The OCC UST Notification Database was searched to locate registered underground storage
tanks (UST) located within the ASTM’s minimum search distance of the subject property and
its adjoining properties. The subject property formerly contained a 1,000 gallon gasoline
UST on the property. The UST was closed on June 30, 1978 and removed August 22, 1995
from the subject property (Appendix K). No leaks were reported to the OCC for the UST.
Following the tank removal the soil was sampled from the wall and the bottom center of the
tank pit. Soil samples collected were below detection limits for TPH (GRO) and (DRO). No
USTs were found on adjoining properties. For a list of registered UST sites, see Appendix L.
4.13 State Institutional Control/Engineering Control Registries
According to the DEQ Brownfield’s Institutional Control Database there are no known
Institutional Control/Engineering Controls in effect for this property (Ref. 16). Following
cleanup of asbestos and lead, the DEQ Site Cleanup Assistance Program will file a deed
notice on the property.
Phase I TBA 17 Former Stilwell Armory
Stilwell, Oklahoma
4.14 State Voluntary Cleanup Sites
The DEQ Online Data Viewer was searched for Voluntary Cleanup Program (VCP) sites within
the required ASTM search distance of ½ mile of the Stilwell Armory (Ref. 11). No VCP sites
are located on or within ½ mile of the subject property.
4.15 State Brownfield Sites
The DEQ Brownfield database was searched for Brownfield sites within the required ASTM
search distance of ½ mile of the Stilwell Armory (Ref. 17). No Brownfield sites were found
within ½ mile of the Stilwell Armory.
4.16 Oil and Gas Records
The subject property is bisected by the section line between Section 28 and 33, T5S, R5E, of
Adair County, Oklahoma. Portions occupy the SE, SE corner of Section 28 and the NE, NE
corner of Section 33. The DEQ performed a search of oil and gas records from the
Oklahoma Corporation Commission’s (OCC) oil and gas records database. There were no
records of wells on the subject property or in adjacent areas.
4.17 Dry Cleaner Databases
DEQ’s historic dry cleaner databases were searched for a radius of one mile around the
subject property (Ref. 21). Five historic dry cleaners were noted for Stilwell, Oklahoma. Pro
Cleaners was located 0.29 miles southeast of the subject property at 11 N. 1st Street,
Thomas’ Clean Cleaners (operated from 1963 to 1985) was located 0.33 miles southeast of
the subject property at 112 S. 2nd Street, and Drive in Cleaners (operated from 1965 to 1966)
is located 0.44 miles southeast of the subject property. The addresses of the following
historic dry cleaners was not descriptive enough to locate the property, they are: Nu-way
Cleaners (operated from 1946 to 1962) located on Main Street in Stilwell, Oklahoma and
Clean Cleaners (operated from 1941 to 1962) had a mailing address of Box 67 in Stilwell,
Oklahoma. To capture present day dry cleaners operating in the area, yellowpages.com
was searched (Ref. 22). One dry cleaner was listed within one mile of the subject property
(Modern Cleaners). Modern Cleaners is located 0.58 miles south of the subject property at
410 S. 2nd Street.
Phase I TBA 18 Former Stilwell Armory
Stilwell, Oklahoma
5.0 Site Reconnaissance and Interviews
5.1 Methodology and Limiting Conditions
A site reconnaissance of the subject property located at 421 W. Pine St., Stilwell, OK was
performed on May 3, 2012. Rachel Francks and Franziska Landes of the DEQ met the
caretaker of the subject property, Ronnie Trentham (City of Stilwell Mayor) at the subject
property. Trentham introduced Francks and Landes to the site and answered questions to
the best of his knowledge on the site. Trentham provided access to the building and
provided background information about the property to the best of his knowledge. All areas
of the building were observed noting any environmental conditions that might need
additional investigation. The entire outside area of the subject property was walked
through for observations that might need additional investigation as well.
5.2 General Site conditions
The former Stilwell Armory Property is composed of a brick building of approximately 11216
square feet that was built in 1954 and does not contain an indoor firing range (IFR). The
building is currently occupied and under renovation by the City of Stilwell. The city uses the
facility for storage and community activities. The property surrounding the building consists
of a residential area and an asphalt parking lot to the south; residential area to the east;
residential area to the south; and a public sports field to the west. The subject property is
in town and paved streets are located to the north, west, and south of the subject property.
The following are general site conditions that were evaluated on the property and adjacent
properties.
5.2.1 Aboveground Storage Tanks (ASTs)
There were no ASTs at the site, nor was there any indication that there had
been at any point.
5.2.2 Landfills and/or Dumping
There was no indication that any part of the property had been used as a landfill
at any point.
5.2.3 Impoundments
There was no standing water on the property. There is a ditch between the
road and the property to the west of the armory, and a large storm drainage
culvert to the south of the property. There was no water in the ditch at the
time of the site visit and the culvert had only a small amount of standing water.
Phase I TBA 19 Former Stilwell Armory
Stilwell, Oklahoma
Ronnie Trentham mentioned that improvements were planned for the culvert,
but did not know when they would be completed. It seems likely the water will
flow with the topographical gradient to the northwest.
5.2.4 Monitoring Wells
There were no wells noted during the site visit. The OWRB data viewer has no
record of wells being located on the property.
5.2.5 Disturbed and Stained Soils
There lot where vehicles were kept was overgrown with grass, so stained soils
would not be visible. The vegetation around the armory appeared to be in good
condition and did not appear distressed, except in an area of high traffic due to
the renovations that were occurring on the armory.
5.2.6 Seeps
No seeps of any kind were observed at the subject property.
5.2.7 Chemical Spills
No evidence of possible chemical spills was observed on the subject property.
5.2.8 Farm Waste
No farm waste was observed at the subject property.
5.2.9 Known Pesticide Misapplication
No known pesticide misapplications were detected during the site visit or during
the supportive research.
5.2.10 Discharges and Runoff from Adjacent Property Affecting the Site
Rainwater runs off to the west side of the subject property. No potential
pollutants were observed on the neighboring properties that may affect the
armory.
Phase I TBA 20 Former Stilwell Armory
Stilwell, Oklahoma
5.2.11 Petroleum Products and Oil and Natural Gas Exploration
No petroleum products or oil and natural gas exploration was observed during
the site visit.
5.2.12 Asbestos
Since many of the State armories were built before the 1970s, there is a high
potential of finding asbestos containing material (ACM) in the armory buildings.
The U.S. began banning the use of asbestos in most building products in the
1970s due to studies confirming the harmful health effects caused by exposure
to airborne asbestos. ACM may be found in the insulation wrapping of the
heating pipes and/or heaters, roofing materials, ceiling tiles, window putty,
mastic, and floor tiles. Floor tiles that are 9”x9” have been found to regularly
contain asbestos.
DEQ’s contractor has conducted an asbestos survey and survey and assessment
for lead in paint and settled dust in the armory. Asbestos was detected in
thermal pipe wrap and fittings, floor tiles, and transite soffits. Pipe with the
wrapping was noted in both bathrooms as well as the water heater closet, and
the drill floor. The pipe wrap is in fair condition and no areas of fraying were
noted.
5.2.13 Lead
Surveys for lead-based paint and lead dust throughout the building have been
conducted by a contractor for the DEQ. The reports indicate that lead based
paint is present in a few rooms on the walls, doors, windows, and roof/ceiling
trusses. There is not an IFR in this building, so any lead dust is most likely due to
deteriorated lead-based paint, or munitions stored in the building. Several
rooms showed lead levels above the HUD acceptable limits.
5.2.14 Transformers/PCB Equipment
There were two transformers observed to the west of the site, and one noted to
the east of the site, on an adjacent property. It is unknown if the transformers
contain PCBs, but they appeared to be in good condition.
5.3 External Observations
The exterior of the building appears to be in good condition. The armory is currently
undergoing renovations. There were no recognized issues with the exterior of the building.
Phase I TBA 21 Former Stilwell Armory
Stilwell, Oklahoma
5.4 Internal Observations
The building is currently unoccupied and was last used by the Oklahoma Army National
Guard to support the military mission. The one story building was constructed from brick in
1954. Before construction of the armory building, the land was owned by the City of Stilwell
and was occupied by a fair grounds. During the site visit on April 11, 2011, the building
appeared to be in good condition though there were signs of water damage along several
walls. No mold was noted during the site visit and Ronnie Trentham said that repairs had
been made to the roof to address the source of the damage. Photographs of the internal
view of the site can be found in Appendix B.
5.5 Interviews
Sheldon Miggleto (Treasurer – City of Stilwell) was listed as the point of contact for the
armory, due to a schedule conflict he was late to the meeting at the armory and so Ronnie
Trentham (Mayor – City of Stilwell) came in his place. Ronnie Trentham and Sheldon
Miggleto have limited knowledge of the site and were listed as the point of contact, because
of their positions with the City of Stilwell. Ronnie Trentham provided access to the building
for DEQ personnel, but had limited information regarding the history of the site. Therefore
interviews were not utilized in determining the operational history of the site.
Phase I TBA 22 Former Stilwell Armory
Stilwell, Oklahoma
6.0 Findings
Summarized below are the major findings from this Targeted Brownfield Assessment and DEQ’s
recommendations. The major findings of the highest environmental concern are presented first.
• The former Stilwell Armory was built in 1954. The land for the building was deeded by the City
of Stilwell to the Oklahoma Military for the State of Oklahoma, for benefit of the Oklahoma
National Guard. The armory is currently owned by the City of Stilwell and will be used for school
and community activities as well as a museum once cleanup activities are complete. A
Memorandum of Agreement (MOA) will be set in place between the OMD and the DEQ. Once
cleanup activities have occurred, a notice of remediation and easement will be filed in the Adair
County Courthouse.
 Four historic dry cleaners were found within a half mile of the site. One currently operating dry
cleaner was found within a mile of the site. It is unknown whether the dry cleaners are
upgradient of the site but it is possible based on surface topography. These are potential
environmental concerns (PEC).
• OCC records show the property formerly contained a 1,000 gallon UST that was closed in June of
1978 and finally removed August 22, 1995. Soil samples collected below the tank were below
detection limits for TPH. The former UST is considered a HREC.
• No National Priority List (NPL), delisted NPL sites, Resource Conservation and Recovery Act
(RCRA) non-corrective action sites (CORRACTS) treatment, storage, and disposal (TSD) listings,
Emergency Response Notification System (ERNS) list, Institutional Controls/Engineering
Controls, or State landfills and/or solid waste disposal sites were found on the subject property
or within the ASTM recommended search radii. No RCRA generators, Voluntary Cleanup (VCP)
sites, or Brownfield sites were found on the subject property. There were no RCRA generators
listed on the subject property or adjacent properties. There were no archived Comprehensive
Environmental Response, Compensation, and Liability Information System (CERCLIS) site listings.
The subject property is on the DEQ Site Cleanup Assistance Program (SCAP) list for cleanup of
lead and asbestos contamination.
• Four facilities with leaking underground storage tanks were found within a ½ mile radius and
potentially upgradient of the subject property.
• No transformers were noted on the site, though three are present on adjoining properties.
Fluorescent lighting ballasts are located throughout the building. The lighting ballasts are all in
good condition. The lighting ballasts may be a source of mercury.
Phase I TBA 23 Former Stilwell Armory
Stilwell, Oklahoma
7.0 Opinion and Recommendations
Due to the past use of the property and potential contamination found on the subject property, the
environmental professionals working on this site believe that cleanup of lead and asbestos will be
necessary.
8.0 Data Gaps
No tribal information was obtained for this assessment. No tax records, city directories, or zoning
records were reviewed for this report. No interviews of the operational history of the building were
conducted. However, this did not affect the ability of the DEQ to make a recommendation on the
subject property.
9.0 Conclusions
DEQ has performed a Phase I Environmental Site Assessment in conformance with the scope and
limitations of ASTM Practice E 1527-05 of the former Stilwell armory located at 421 W. Pine St.,
Stilwell, Oklahoma. Any exceptions to, or deletions from, this standard are described in Section 10.0
of this report. Recognized environmental conditions on this property include lead-based paint and
asbestos contamination throughout the building.
The information provided in this assessment is to assist the City of Stilwell in its revitalization
planning as well as meet the All Appropriate Inquiry requirement of the landowner liability
protections under the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA, better known as Superfund – Ref. 2), as provided in the Small Business Relief and
Brownfields Revitalization Act of 2002 (Public Law 107-118, Subtitle B – Ref. 3).
10.0 Additional Services
In addition to this Phase I Targeted Brownfield Assessment, DEQ has provided sampling analysis of
potential asbestos, lead-based paint, and lead dust sources including the remediation of the
building.
11.0 Deviations
The following deviations from ASTM Practice E 1527-05 occur in this Phase I Targeted Brownfield
Assessment. No tax records, city directories, or zoning records were reviewed for this report.
Phase I TBA 24 Former Stilwell Armory
Stilwell, Oklahoma
12.0 References
1. U.S. Environmental Protection Agency. (2008). Oklahoma Brownfields Assistance Agreement (No
#RP96681001-0). Unpublished Document. State of Oklahoma: Oklahoma City, Oklahoma.
2. U.S. Environmental Protection Agency. (1980). Comprehensive Environmental Response, Compensation,
and Liability Act. (Public Law 96-510). Washington, DC: U.S. Government Printing Office.
3. U.S. Environmental Protection Agency. (2002). Small Business Liability Relief and Brownfields Revitalization
Act. (Public Law 107-118, Subtitle B). Washington, DC: U.S. Government Printing Office
4. ASTM International. (2005). Water and Environmental Technology: Phase I Environmental Site Assessment
E 1527 – 05. Baltimore, Maryland.
5. Environmental Protection Agency. EPA National Priority List. Last accessed March 19, 2013.
http://www.epa.gov/superfund/sites/npl/status.htm.
6. Environmental Protection Agency. EPA Deleted National Priority List. Last accessed March 19, 2013.
http://www.epa.gov/superfund/sites/query/queryhtm/npldel.htm
7. Environmental Protection Agency. CERCLIS current and archived sites. Last accessed March 19, 2013.
http://cfpub.epa.gov/supercpad/cursites/srchsites.cfm.
8. Environmental Protection Agency. RCRA database. Last accessed March 19, 2013. RCRA database.
http://www.epa.gov/enviro/html/rcris/rcris_query_java.html.
9. National Response Center. Emergency Response Notification System. Last accessed March 19, 2013.
http://www.nrc.uscg.mil/foia.html.
10. Oklahoma Department of Environmental Quality. State Landfill site list. Last accessed March 22, 2013.
http://www.deq.state.ok.us/LpDnew/swindex.html.
11. Oklahoma Department of Environmental Quality. DEQ ArcGIS Viewer. Last accessed March 22, 2013.
http://gis.deq.ok.gov/flexviewer/
12. Federal Emergency Management Association (FEMA). FEMA Issued Flood Maps. Last accessed March 22,
2013.
http://www.msc.fema.gov/webapp/wcs/stores/servlet/CategoryDisplay?catalogId=10001&storeId=10001
&categoryId=12001&langId=-1&userType=G&type=1&future=false
13. Oklahoma Department of Environmental Quality. RCRA NOTIFIERS sorted by county and then city. Last
accessed March 19, 2013. http://www.deq.state.ok.us/LPDnew/HW/Notifiers/notifiersbycountycity.pdf.
14. United States Department of Agriculture, Natural Resources Conservation Service. (n.d.). Web soil survey.
Last accessed March 22, 2013. http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx
15. Oklahoma Water Resources Board. OWRB Custom Map Viewer-Data Driven Map Viewers. Last accessed
March 21, 2013. http://www.owrb.ok.gov/maps/server/wims.php.
16. Oklahoma Department of Environmental Quality. Oklahoma Brownfield’s Institutional Control Database.
Last accessed March 21, 2013.
http://www.deq.state.ok.us/lpdnew/Brownfields/IC%20Documents/IC%20Database%20edit.html
17. Oklahoma Department of Environmental Quality. Oklahoma Brownfield’s Public Record. Last accessed
March 22, 2013. http://www.deq.state.ok.us/lpdnew/Brownfields/PublicRecordBrownfields.pdf
Phase I TBA 25 Former Stilwell Armory
Stilwell, Oklahoma
18. Digital Sanborn Maps 1867-1970. Stilwell, Adair County, OK. (1946). Last Accessed March 22, 2013.
http://sanborn.umi.com/
19. Johnson, Kenneth, & Luza, Kenneth. Oklahoma Geological Survey, (2008). Earth sciences and mineral
resources of Oklahoma (Educational Publication No. 9). Norman, OK: University of Oklahoma Printing
Services.
20. Rachel Francks, Oklahoma Department of Environmental Quality, interview notes with Stilwell Mayor,
Ronnie Trentham and City Clerk, May 3, 2012, Stilwell Armory.
21. Oklahoma Department of Environmental Quality. Historic Dry Cleaner Databases. DEQ Archives. Last
viewed March 22, 2013.
22. YP Intellectual Property LLC. http://www.yellowpages.com Last viewed March 22, 2013.

TARGETED BROWNFIELD ASSESSMENT
For
Oklahoma Army National Guard
Former Stilwell Armory
Stilwell, Oklahoma
ASTM E 1527-05
Phase I Environmental Site Assessment
All Appropriate Inquiry
Prepared by:
April 19, 2013
Phase I TBA 2 Former Stilwell Armory
Stilwell, Oklahoma
Table of Contents
1.0 Executive Summary……………………………………………………………………………………………………..…………….…………………….. 4
2.0 Introduction………………………………………………………………………………………………………………..…………….………………..….. 6
2.1 Purpose …………………………………………………………………………………………….……..…………………………..…………………… 6
2.2 Detailed Scope-of-services ……………………………………………………………….…………………………………..…………………… 6
2.3 Significant Assumptions …………………………………………………………………….…………………..…………..…………………….. 6
2.4 Limitations and Exceptions ………………………………………………………………………….……………………..…………………….. 7
2.5 Special Terms and Conditions ………………………………………………………………………………..………………………………….. 7
3.0 Site Characterization and History ………………………………………………………………………………………………….…………..…… 8
3.1 Location and Legal Description ………………………………………………………………………………………………………………….. 8
3.2 Site and Vicinity Characterization …………………………………………………………………………..……………………………..….. 8
3.3 Descriptions of Structures, Roads and Other Improvements ………………………………..……………………………….……. 9
3.4 Owner, Property Manager, and Occupant Information ………………………………………………………………..…………….… 9
3.5 Information Reported by User Regarding Environmental Lien or Specialized Knowledge or Experience ….…….. 9
3.6 Commonly Known or Reasonable Ascertainable Information ………………………….…….…………………..……………….. 9
3.7 Valuation Reduction for Environmental Issues ……………………………………………………….………………………………….. 10
3.8 Current Use of Property …………………………………………………………………………………………………..……………………….. 10
3.9 Past Use of Property ………………………………………………………………………………………………………………………..……….. 10
3.9.1 Review of Aerial Photos …………………………………………………………………………………..………………………………. 10
3.9.2 Fire Insurance Maps ………………………………………………………………………………………………………………..……….. 11
3.10 Current and Past Use of Adjoining Properties ………………………………………………….…….………………………………….. 11
3.11 Environmental (Physical) Setting ……………………………….……………………..………………………………………………..…….. 11
3.11.1 Surface Water Characteristics ……………………………………………………………………….…………………………..…….. 11
3.11.2 Subsurface Geological Characteristics …………………………..………………………….…….………..……………….…….. 12
3.11.3 Ground Water Characteristics ……………………………………………………………………….……………………..………….. 12
3.11.4 Air Characteristics ……………………………………………………………………………………………………………….………….. 13
4.0 Records Review ………………………………………………………………………………………….……………….………………………..……….. 14
4.1 Federal National Priorities List (NPL) ……………………………………………………………………..………………………...……….. 14
4.2 Federal CERCLIS List ……………………………………………………………………………………………….……………………………….. 14
4.3 Federal RCRA CORRACTs List ………………………………………………………………………….…..……………………………..…….. 14
4.4 Federal RCRA non-CORRACTS TSD List …………………………………………………….………………………………………….…….. 14
4.5 Federal RCRA Generators List ……………………………………………………………………………………...………………………….. 15
4.6 Federal ERNS List …………………………………………………………………………………………………………………………………….. 15
4.7 Federal Institutional Control/Engineering Control Registries …………………………………………..………………..……….. 15
4.8 State-Equivalent NPL ………………………………………………………………………………………….……..………………..………….. 15
4.9 State-Equivalent CERCLIS ………………………………………………………………………………..……………………………..……….. 15
4.10 State Landfill and/or Solid Waste Disposal Sites ……………………………………………………..……………………..………….. 15
4.11 State Leaking UST List ………………………………………………………………………………………….…………………………..……….. 16
4.12 State Registered UST Sites ……………………………………………………………………………………….……………………………….. 16
4.13 State Institutional Control/Engineering Control Registries …………………………………….……..………………..………….. 16
4.14 State Voluntary Cleanup Sites ………………………………………………………………………….……….…………………..………….. 17
4.15 State Brownfield Sites ……………………………………………………………………………………..……….…………………..………….. 17
4.16 Oil and Gas Records …………………………………………………………………………………………….……….…………………..………….. 17
4.17 Dry Cleaner Databases ………………………..………………………..………………………..…………………………………....………… 17
5.0 Site Reconnaissance and Interviews ……………………………………………………………………..……….……………….…………….. 18
5.1 Methodology and Limiting Conditions ……………………………………….……………………………..……………………………….. 18
5.2 General Site Conditions ……………………………………………………………….…………………………………………………..……….. 18
5.2.1 Above Ground Storage Tanks (ASTs) …………………………………………………………..……………………………..………. 18
5.2.2 Landfills and/or Dumping …………………….…………………………………………………………….………………………..……. 18
5.2.3 Impoundments ……………………………..…………………………………………………………………..………………….……….. 18
Phase I TBA 3 Former Stilwell Armory
Stilwell, Oklahoma
5.2.4 Monitoring Wells ……………………………………………………………………………………………..……………………………… 19
5.2.5 Disturbed and Stained Soil ……………………………………………………………………………….……………….……………… 19
5.2.6 Seeps …………………………………………………………………………………………………………….………………….…………….. 19
5.2.7 Chemical Spills …………………………….………………………………………………………………..………………….…………….. 19
5.2.8 Farm Waste ……………………………………………………………………………………………………………………..……………….. 19
5.2.9 Known Pesticide Misapplication ………………………………………………………………………………………….…………….. 19
5.2.10 Discharges and Runoff from Adjacent Property Affecting the Site ………………………………..…………….……….. 19
5.2.11 Petroleum Products and Oil and Natural Gas Exploration ……………………………………..…..……………..……….. 20
5.2.12 Asbestos ………………………………………………………………………………………………………………………………………….. 20
5.2.13 Lead ……………………………………………………………………………………………………………………..……………….………….. 20
5.2.14 Transformers/PCB Equipment ………………………………………………………………………..…….……………….………….. 20
5.3 External Observations …………………………………………………………….………………………………..…..………………………….. 20
5.4 Internal Observations ………………………..…………………………………………………………………….……..……………………….. 21
5.5 Interviews ……………………………………………………………………………………………….…………………………………..………….. 21
6.0 Findings ……………………………………………………………………………………………………………………….……………………..………….. 22
7.0 Opinion and Recommendations …………………………………………………………………………………..……………………..………….. 23
8.0 Data Gaps …………………………………………………………………………………………………………………………………………..………….. 23
9.0 Conclusions ………………………………………………………………………………………………………………….…………………..…………….. 23
10.0 Additional Services ……………………………………………………………………………………………………………………………..………….. 23
11.0 Deviations …………………………………………………………………………………………………………………………………………..………….. 23
12.0 References …………………………………………………………………………………………………………………….………………………..……… 24
Appendices
A. Qualifications of Environmental Professionals
B. Photographs from site visit/Site notes
C. Aerial Photographs
D. FEMA Flood Zone Map
E. Sanborn Map
F. USGS Topographical Map / Site Maps
G. Deeds
H. ERNS Records for Stilwell, OK
J. RCRA Records for Stilwell, OK
K. Underground Storage Tank Removal Documents
L. Oklahoma Corporation Commission UST records
M. Oklahoma Water Resource Board Water Wells
N. Air Quality Permitted Facilities
O. Memorandum of Agreement between Oklahoma Department of Environmental Quality and the City of
Stilwell
P. Oklahoma Military Department Environmental Office Records for Madill Armory, 421 W. Pine St., Stilwell,
OK.
Q. Site Cleanup Assistance Program Lead Based Paint and Asbestos Inspection Documents
Background and Disclaimer
Phase I TBA 4 Former Stilwell Armory
Stilwell, Oklahoma
1.0 Executive Summary
On May 3, 2012, Rachel Francks and Franziska Landes of the Oklahoma Department of
Environmental Quality (DEQ) performed site reconnaissance of the former Stilwell National Guard
Armory located at 421 West Pine St., Stilwell, Adair County, Oklahoma, as part of a Targeted
Brownfield Assessment (TBA). The subject property is situated on the southern side of the City of
Stilwell and is part of a school complex that includes sports fields and is used by the City of Stilwell
as a meeting and activity center. The purpose of the TBA was to identify potential environmental
concerns by reviewing historical data, regulatory information, and by performing a visual inspection
of the site and surrounding area. The following is an executive summary of the environmental site
assessment results:
 Recognized environmental conditions (REC) include insulation around pipes that are asbestos
containing materials (ACMs), lead-based paint (LBP), and lead dust from firearms and from
degrading LBP.
 Four historic dry cleaners were found within a half mile of the site. One currently operating dry
cleaner was found within a mile of the site. It is unknown whether the dry cleaners are
upgradient of the site but it is possible based on surface topography.
 The former Stilwell National Guard Armory was built in 1954. The property was managed and
maintained by the Oklahoma Military Department (OMD) on behalf of the State of Oklahoma.
Ownership of the subject property has been transferred to the City of Stilwell as of June 15,
2011. The City of Stilwell is currently working on clean up and development of the site for use
by the City of Stilwell as a community center and the Veterans of Foreign Wars (VFW) as a
museum. Building repair has begun and once cleanup activities have occurred, the City of
Stilwell will begin occupying the building.
 There is one large building on the site. The offices and class rooms surround the motor pool
maintenance area and the drill floor. All equipment has been removed, with the exception of a
stove, heating and cooling units and the water heater. There are pipes in the latrines and the
janitor’s closet to the east of the drill floor that are surrounded by insulation that has been
confirmed as ACM. The pipes extend along a wall around the drill floor to the motor pool on the
west side of the building. The asbestos pipe wrap appeared to be in good condition.
 Adjoining properties consist of the sports fields, and residential area. Historical aerial
photographs beginning in 1939 show the subject property as fair grounds and residential. Aerial
photos from 1995 – 2010 show the area around the location to be occupied by the sports fields
and residential housing.
 The property is located centrally within Stilwell, and Sanborn Fire Insurance maps show the
subject property to contain a fair building and a park on a neighboring property. The fire
insurance maps show the surrounding areas to be residential.
 No National Priority List (NPL), delisted NPL sites, Resource Conservation and Recovery Act
(RCRA) non-corrective action sites (CORRACTS) treatment, storage, and disposal (TSD) listings,
Emergency Response Notification System (ERNS) list, Institutional Controls/Engineering
Phase I TBA 5 Former Stilwell Armory
Stilwell, Oklahoma
Controls, or State landfills and/or solid waste disposal sites were found on the subject property
or within the ASTM recommended search radii. No RCRA generators, Voluntary Cleanup (VCP)
sites, or Brownfield sites were found on the subject property. There were no archived
Comprehensive Environmental Response, Compensation, and Liability Information System
(CERCLIS) site listings within a ½ mile of the subject property.
 There was one underground storage tank (UST) on site. It had a 1,000 gallon capacity and was
used to store gasoline. The tank was closed in 1978 and removed in 1995 and the case was
closed by the Oklahoma Corporation Commission (OCC). At the time of removal, the soil below
the tank and to the side was tested for total petroleum hydrocarbons (TPH). The results showed
all tested contaminants to be below detection limits. When pulled the tank was in good
condition with no holes. The tank pit was filled with clean soil. During the site visit on May 3,
2012, there was no sign of the UST or soil staining and the pump island had been removed as
well. The UST is considered a historical recognized environmental condition (HREC).
 OCC Oil and gas exploration records were searched for wells on the subject property and
adjoining properties. There was no record of oil and gas production on the subject property or
any adjoining sites.
 Transformers were noted to the north, east, and south of the armory. They are off the property
and it is unknown if they contain polychlorinated biphenyls (PCBs), but the units appear new
and in good condition. Fluorescent lighting ballasts are located throughout the offices in the
building. The lighting ballasts are all in good condition in most rooms. The lights in the drill floor
and the garage are old incandescent bulbs and new fluorescent installations. All fluorescent
bulbs contain mercury and should be handled as Universal Waste unless documentation and/or
sampling demonstrate they are not hazardous.
 Four LUSTs were found within a half mile of the subject property. It is unknown whether the
LUSTs are upgradient of the site but it is possible based on surface topography.
Phase I TBA 6 Former Stilwell Armory
Stilwell, Oklahoma
2.0 Introduction
The State of Oklahoma Department of Environmental Quality (DEQ) under a Brownfield Assistance
Agreement (No. RP96681001-0) (Ref. 1) with the U.S. Environmental Protection Agency (EPA)
conducted a Targeted Brownfield Assessment of a property located at 421 West Pine St., Stilwell,
Adair County, Oklahoma.
2.1 Purpose
The purpose of this assessment is to look at the environmental conditions within the target
area and provide this information to the City of Stilwell as well as meet the All Appropriate
Inquiry requirement of the landowner liability protections under the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA, better known as
Superfund – Ref. 2), as provided in the Small Business Relief and Brownfield’s Revitalization
Act of 2002 (Public Law 107-118, Subtitle B – Ref. 3). The purpose of a Phase I
Environmental Site Assessment is to identify, to the extent feasible, recognized
environmental conditions in connection with the target property through a systematic
review of readily available information sources and a site reconnaissance.
DEQ is providing technical assistance to the project by evaluating the environmental
condition of the property prior to the City of Stilwell converting the armory for use as a
community center and by the VFW as a museum. Funding for this assessment has been
provided by the U.S. Environmental Protection Agency (EPA).
2.2 Detailed Scope of Services
DEQ examined the current use of the property and identified the historical uses of the
property to determine if recognized environmental conditions exist. DEQ examined
historical documents, governmental databases, oil and gas records, aerial photographs,
Sanborn Fire Insurance Maps, and conducted interviews and a site reconnaissance of the
area. A good faith effort was made to identify possible environmental conditions that might
affect the development of the property.
2.3 Significant Assumptions
History and knowledge of the subject property shows that the building was used as a
National Guard Armory. Prior to armory construction in 1954, the property was used as a
County Fairgrounds. There has been no oil and gas exploration on the property according to
OCC records.
Since the building was constructed in 1954, the building may contain ACM. The U.S. began
banning the use of asbestos in most building materials in the 1970s due to studies
confirming the harmful health effects caused by exposure to airborne asbestos. Insulation
Phase I TBA 7 Former Stilwell Armory
Stilwell, Oklahoma
observed in the building during the site reconnaissance conducted on May 3, 2012, has been
confirmed to contain asbestos. DEQ’s contractors performed a lead and asbestos survey on
the property. Lead-based paint, lead dust, and asbestos containing materials were found in
the building. See Sections 5.2.12 and 5.2.13 for more information on asbestos and lead
found in the building.
2.4 Limitations and Exceptions
The purpose of an environmental site assessment is to identify actual or potential
“recognized environmental conditions” that may result in liability, land use restrictions, or
cause delays in revitalization. The ASTM Phase I Environmental Site Assessment E 1527 – 05
(Ref. 4) is the minimum standard for environmental due diligence in the real estate industry
and meets the standard for All Appropriate Inquiry under the Small Business Liability Relief
and Brownfields Revitalization Act of 2002. A diligent effort in accordance with generally
accepted good commercial and customary standards and practices was undertaken to
identify the “recognized environmental conditions” that might affect the revitalization
project. However, the identification of old hazardous waste sites is an evolving process;
therefore, DEQ cannot state with absolute certainty that no other potential hazardous
waste sites are located in the area. This assessment was conducted under constraints of
time, cost, and scope and reflects a limited investigation and evaluation. It reflects the
normal degree of care and skill that is ordinarily exercised by environmental professionals
conducting business in this or similar localities. In no event shall the DEQ or its employees
be liable for any damages, injury, loss, cost or expense whatsoever arising in connection
with the use or reliance on the information contained in this report, except as otherwise
provided by law.
The information in this report is based on a review of governmental records, interviews with
knowledgeable representatives of the property, information provided by the City of Stilwell,
and observations of the environmental professional. The result of this assessment, as
written in this report, is valid as of the date of report. The assessment does not include
sampling of rock, groundwater, surface water, or air. For qualifications of environmental
professionals see Appendix A.
2.5 Special Terms and Conditions
This assessment report has been prepared for the City of Stilwell by the DEQ using EPA
funding. Information about this report will be provided to the EPA for its files. This report
and the working file are public record and subject to the Oklahoma Open Records Act and
the federal Freedom of Information Act.
Phase I TBA 8 Former Stilwell Armory
Stilwell, Oklahoma
3.0 Site Characterization and History
3.1 Location and Legal Description
The subject property is located at 421 West Pine St. in Stilwell, Oklahoma. This property
consists of approximately two and a half acres of land and contains the former National
Guard Armory building. A site map and topographical map depicting the property have
been provided in Appendix F.
The subject property is located in NE ¼ SE ¼ of Section 34, T16N, R25E, Adair County,
Oklahoma. The armory building’s legal description is:
The West half of Lot 2, and all of Lots 3 and 4 and the West half of Lot 5 of Block 17, and the
West 150 feet of an alley way 20 feet wide extending East and West within Block 17, and a tract
of land described as follows: Beginning at the Northwest comer of Lot 3 in Block 17 of the
original town of Stilwell, Oklahoma; thence running in a Southerly direction along the West line
of said Block 17, a distance of 300 feet to the North line of Pine Street; thence in a Westerly
direction along the North line of Pine Street extended, a distance of 60 feet; thence in a
Northeasterly direction parallel with the West line of said Block 17, a distance of 300 feet the
South line of Popular Street; thence in an Easterly direction 60 feet to place of beginning, all in the
original Town of Stilwell, Oklahoma, according to the U.S. Government Survey thereof.
3.2 Site and Vicinity Characterization
The former Stilwell Armory was built in 1954. According to Adair County land records, the
land for the building was owned by the City of Stilwell and was deeded to the State of
Oklahoma for the construction of the Oklahoma National Guard Armory on September 10,
1954 (see Appendix G). The subject property is a tract of land about 1.1 acres in size, and is
located at 412 West Pine Street, Stilwell, Oklahoma. It is bounded by Poplar St. on the
north, 5th Ave on the west, and Pine St on the south. The areas where the subject property
and adjacent properties are located are best characterized by residential development.
Residences surround the subject property to the north, east and south, and a sports field is
to the west.
Asbestos and LBP have been confirmed in the building by DEQ contractors. Utilities that
serve the subject property are the City of Stilwell for electricity, North East Oklahoma Public
Facilities Authority (NEOPFA) for gas service, and the City of Stilwell provides water and
sewer services to the armory according to Ronnie Trentham (Mayor of the City of Stillwell).
A review of the topographical map indicated that the surface elevation of the site is
approximately 340 feet above mean sea level. The topographical gradient is to the
northwest, toward Caney Creek. Caney Creek is located approximately 0.4 miles from the
site to the west. The topographical map can be found in Appendix F.
Phase I TBA 9 Former Stilwell Armory
Stilwell, Oklahoma
3.3 Description of Structures, Roads, and Other Improvements
The structure of the armory is in good condition. The floor was in good condition, though
there are cracks in some of the tiles and paint is present below the tiles. Yellow mastic was
noted under damaged tiles. Windows were in good condition at the Armory and are not
original to the building and were recently replaced according to Ronnie Trentham. Roads
surrounding the Armory and the front parking lot are in good condition. The rear parking
area is surrounded by chain link fence and is covered in grass. The only area of stressed
vegetation seemed to be associated with the increased traffic from the renovation being
performed on the building. Adjacent properties, which consist of residential and sports
fields, are in good condition. Throughout the facility, there are floor drains. Based on
previous armories, it is thought that these drains lead into the city sanitary sewage pipes,
but at the time of this report that could not be confirmed.
3.4 Owner, Property Manager, and Occupant Information
The subject property is owned by the City of Stilwell and is currently occupied by groups
using the building for sports classes and events, at the time of the inspection the armory
was undergoing renovation. Large pallets of supplies were stacked around the outside of
the building and in some areas of the drill floor. DEQ Site Cleanup Assistance Program
(SCAP) is in charge of identifying environmental hazards and conducting the cleanup of
asbestos and lead in the Armory. The Military department transferred ownership of the
armory to the City of Stilwell prior to completion of remedial activities (Appendix O).
3.5 Information Reported by User Regarding Environmental Lien or Specialized Knowledge or
Experience
The property owner and/or representatives reported no environmental liens on the subject
property, and had no specialized knowledge or experience regarding recognized
environmental conditions. The DEQ conducted a search for environmental liens at the Adair
County Courthouse. No environmental liens or use limitations were reported for the subject
property, and it does not appear in the Brownfield IC database.
3.6 Commonly Known or Reasonably Ascertainable Information
Ronnie Trentham, Stilwell City Mayor, indicated that to the best of his knowledge the land
had been owned only by the City of Stilwell who then provided the land for construction of
the armory. It is known within the community that the building functioned as a National
Guard Armory.
Phase I TBA 10 Former Stilwell Armory
Stilwell, Oklahoma
3.7 Valuation Reduction for Environmental Issues
Valuation of the property is outside the scope of this assessment. A professional appraiser
should be consulted to place a value on the property.
3.8 Current Use of the Property
The property is currently being used as a community center and area for sports classes and
events by the City of Stilwell. Renovation is currently underway on the property.
3.9 Past Use of the Property
3.9.1 Review of Aerial Photographs
Historic aerial photographs were searched to view the changes to the property
over time. The 1939 aerial photograph was found at the Oklahoma Department
of Libraries. The aerial photographs from 1995, 2003, 2005, and 2012 were
found on Google Earth. Aerial photographs from 1939, 1995, 2003, 2005, and
2012 were obtained. All aerial photographs are located in Appendix C. The
following represents a summary of what was found at the subject property from
each photograph.
1939 aerial photograph
The 1939 aerial photograph shows the subject property to be fair grounds with
park land to the west. There is residential property to the north, east and south
of the property. There is one structure visible on the subject property, which
are most likely the fairgrounds buildings.
1995 aerial photograph
The 1995 aerial photograph shows the subject property with the Armory. There
is a sports field to the west of the subject property. The property is largely
surrounded by residential areas to the north, east and south.
2003 aerial photograph
The 2003 aerial photograph shows the subject property with the Armory. There
is a sports field to the west of the subject property. The property is largely
surrounded by residential areas to the north, east and south.
Phase I TBA 11 Former Stilwell Armory
Stilwell, Oklahoma
2005 aerial photograph
The 2005 aerial photograph shows the subject property with the Armory. There
is a sports field to the west of the subject property. The property is largely
surrounded by residential areas to the north, east and south.
2012 aerial photograph
The 2005 aerial photograph shows the subject property with the Armory. There
is a sports field to the west of the subject property. The property is largely
surrounded by residential areas to the north, east and south.
3.9.2 Fire Insurance Maps
The 1925 Sanborn maps show the area occupied by fairground buildings. The
areas to the east, south and north appear to be occupied by residential
structures. The area to the west isn’t shown on the smaller maps, but on the
key sheet the area appears as a park.
3.10 Current and Past Uses of Adjoining Properties
Currently the areas surrounding the site are residential and sports fields. The areas to the
north, east and south have always been residential and are still residential. The area to the
west has historically been a park and is currently occupied by a sports field.
3.11 Environmental (Physical) Setting
DEQ reviewed several sources to obtain information on the physical setting of the subject
property and its surrounding areas. These sources include: The United States Department
of Agriculture Adair County Soil Survey, Oklahoma Water Resource Board data viewer, and
the Federal Emergency Management Association. Review of the physical setting of the area
is to evaluate the sensitivity of the hydrogeology to potential contamination from sources
either on or near the site.
3.11.1 Surface Water Characteristics
The topography of the area is relatively flat. The former Stilwell Armory is located at
a surface elevation of approximately 350 feet above mean sea level. The
topographical gradient is to the west, toward Caney Creek. Caney Creek is located
approximately 0.4 miles southwest of the site.
Phase I TBA 12 Former Stilwell Armory
Stilwell, Oklahoma
According to the Federal Emergency Management Association (FEMA), the subject
property is in an area outside the 500 year flood plain A map of this information is
located in Appendix D.
3.11.2 Subsurface Geological Characterization
Adair County is mainly comprised of the Boston Mountains and the Ozark Plateau
within the Ozark Uplift regions. This area is characterized by a deeply dissected
plateau formed by limestones and cherts, and capped in places by Pennsylvanian
sandstones. Caves and sinkholes may occur in this area (Ref. 19).
According to the Soil Survey of Adair County, Oklahoma, the subject property
consists of Apperson silty clay loam. Apperson silty clay loam comprises 100% of
the subject property area of interest and is characterized by a slope of 0 to 1
percent, a water table depth of over 18 to 24 inches, and high water capacity (Ref.
14).
3.11.3 Ground Water Characteristics
The hydrogeology as reported by the Oklahoma Water Resources Board (OWRB)
indicates the site is on the Boone which is a minor groundwater basin, and the
Rubidoux which is a major groundwater basin. The Boone basin is unfavorable for
production of groundwater due to its low yield of 10 gpm. The Rubidoux basin is a
bedrock basin with a strongly varying saturated thickness. The Rubidoux is generally
unfavorable for groundwater production due to high chloride levels in the water.
The aquifer vulnerability for the area around the site is high for the Boone Basin and
low for the Rubidoux.
The OWRB Reported Well Log Viewer was utilized to make a map of groundwater
and monitoring wells within a half mile radius of the subject property. There are a
number of wells within 0.50 miles of the property, mostly used for site assessment
and water monitoring purposes. The closest groundwater well is 0.2 miles south of
the subject property, and is used for domestic water purposes. For a list and map of
wells that are within 0.50 miles of the subject property, see Appendix M.
The subject property obtains its drinking water from the City of Stilwell Utilities,
which uses surface water as its water source. The City of Stilwell is currently using
Stilwell City Lake, to the southwest of the city, as its water source.
3.11.4 Air Characteristics
No air emissions were noticed at the subject property or the adjoining properties.
The DEQ dataviewer database was searched for Air Quality Permitted Facilities
Phase I TBA 13 Former Stilwell Armory
Stilwell, Oklahoma
(AQPF). No AQPF were found within a 1 mile radius from the subject property.
There is a potential for lead dust and asbestos emissions from the subject property.
Phase I TBA 14 Former Stilwell Armory
Stilwell, Oklahoma
4.0 Records Review
A regulatory database search was conducted by DEQ. This search included, at a minimum, those
records and distances from the site dictated as appropriate in the ASTM standard. DEQ performed a
review of available federal and state databases to assess whether the subject property or proximate
properties were listed as having environmental concerns, which could have an adverse impact on
the subject property. The following provides a summary of the databases reviewed.
4.1 Federal National Priorities List (NPL)
A search of the Environmental Protection Agency’s NPL database shows no current NPL sites
within a mile radius of the subject property (Ref. 5). The subject property is not an NPL site.
The database also shows no delisted NPL sites within a half mile radius of the subject
property.
4.2 Federal CERCLIS List
The EPA database for Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) Information Systems (CERCLIS) was searched for active and archived CERCLIS
sites on and near the subject property (Ref. 7). The ASTM’s recommended search radius for
the subject property for both active and archived CERCLIS sites is ½ mile. No CERCLIS sites
were found within a ½ mile radius of the site. The property is not listed as an active CERCLIS
site.
The subject property is also not listed in the archived CERCLIS site list. There are no archived
sites within a ½ mile of the subject property.
4.3 Federal RCRA CORRACTs List
The EPA database for Resource Conservation and Recovery Act (RCRA) facilities subject to
corrective action was searched within the ASTM’s required minimum distance of one mile of
the subject property (Ref. 8). No RCRA CORRACT facility was found within the one-mile
radius of the subject property.
4.4 Federal RCRA non-CORRACTS TSD List
The EPA database for RCRA facilities not subject to corrective action was searched within
the ASTM’s required minimum distance of ½ mile of the subject property (Ref. 8). No RCRA
non-CORRACT Treatment, Storage and Disposal (TSD) sites are within the ½ mile radius of
the subject property.
Phase I TBA 15 Former Stilwell Armory
Stilwell, Oklahoma
4.5 Federal RCRA Generators List
The EPA RCRA Notifiers database was searched for RCRA generators within the ASTM’s
required minimum search distance of the subject property and adjoining properties (Ref. 8).
The subject property did not have any RCRA notifiers or generators. There were also no
facilities found near the subject property. No large quantity generators were reported
within the subject property and its adjoining properties. For a list of local generators
outside of the search radius see Appendix (J).
4.6 Federal ERNS List
The Emergency Response Notification system (ERNS) maintained by the National Response
Center was searched for any hazardous substance releases or spills within the subject
property (Ref. 9). ASTM requires a minimum search distance of property only when
identifying ERNS cases. No ERNS sites were reported within the property or the adjoining
properties. For a list of local incidents outside of the search radius see Appendix (H).
4.7 Federal Institutional Control/Engineering Control Registries
Federal institutional control/engineering control registries are still under development.
There are no known Institutional Control/Engineering Controls in effect for this property.
Following cleanup of asbestos and lead, the DEQ Site Cleanup Assistance Program will file a
deed notice on the property.
4.8 State-Equivalent NPL
DEQ does not have a State-equivalent NPL database. Oklahoma does not have a State
Superfund law to establish a State-equivalent NPL database.
4.9 State-Equivalent CERCLIS
DEQ does not have a State-equivalent CERCLIS database.
4.10 State Landfill and / or Solid Waste Disposal Sites
DEQ regulates landfills and solid waste disposal sites across the State of Oklahoma (Ref. 10).
State landfills and solid waste disposal facilities were searched in the DEQ database within
the ASTM required minimum distance of ½ mile from the subject property. No permitted
landfills or solid waste disposal facilities are located within the search distance of the subject
property.
Phase I TBA 16 Former Stilwell Armory
Stilwell, Oklahoma
4.11 State Leaking UST List
The OCC UST Notification Database and OWRB’s Online Data viewer were searched to locate
any known leaking underground storage tank (LUST) sites located within the ASTM’s
minimum search distance of a ½ mile of the subject property. Four LUST sites were found
within the ½ mile radius. The following sites are listed and described below.
 Ez Mart #550, located at 110 North 2nd St., is south east of the subject property. The
three of the tanks are listed as permanently out of service, two of the tanks are listed as
currently in service, and the cases are all closed, but there are no other records
regarding these LUSTs. The LUST case Facility ID number is 064-1952.
 Harvest Foods, located at 419 North 2nd St., is north east of the subject property. The
two tanks are listed as permanently out of service and backfilled. The cases are closed.
The LUST case Facility ID number is BF-0215.
 Olives Station, located at North 2nd St. and Hwy 59, is northeast of the subject property.
The tanks are listed as permanently out of service and the cases are closed. The LUST
case ID number is 064-2284.
 Stilwell Foods, located at 5 East Walnut St., is south east of the subject property. The
tanks are listed as permanently out of service and the case is closed. The LUST case
Facility ID number is 064-PN.
4.12 State Registered UST Sites
The OCC UST Notification Database was searched to locate registered underground storage
tanks (UST) located within the ASTM’s minimum search distance of the subject property and
its adjoining properties. The subject property formerly contained a 1,000 gallon gasoline
UST on the property. The UST was closed on June 30, 1978 and removed August 22, 1995
from the subject property (Appendix K). No leaks were reported to the OCC for the UST.
Following the tank removal the soil was sampled from the wall and the bottom center of the
tank pit. Soil samples collected were below detection limits for TPH (GRO) and (DRO). No
USTs were found on adjoining properties. For a list of registered UST sites, see Appendix L.
4.13 State Institutional Control/Engineering Control Registries
According to the DEQ Brownfield’s Institutional Control Database there are no known
Institutional Control/Engineering Controls in effect for this property (Ref. 16). Following
cleanup of asbestos and lead, the DEQ Site Cleanup Assistance Program will file a deed
notice on the property.
Phase I TBA 17 Former Stilwell Armory
Stilwell, Oklahoma
4.14 State Voluntary Cleanup Sites
The DEQ Online Data Viewer was searched for Voluntary Cleanup Program (VCP) sites within
the required ASTM search distance of ½ mile of the Stilwell Armory (Ref. 11). No VCP sites
are located on or within ½ mile of the subject property.
4.15 State Brownfield Sites
The DEQ Brownfield database was searched for Brownfield sites within the required ASTM
search distance of ½ mile of the Stilwell Armory (Ref. 17). No Brownfield sites were found
within ½ mile of the Stilwell Armory.
4.16 Oil and Gas Records
The subject property is bisected by the section line between Section 28 and 33, T5S, R5E, of
Adair County, Oklahoma. Portions occupy the SE, SE corner of Section 28 and the NE, NE
corner of Section 33. The DEQ performed a search of oil and gas records from the
Oklahoma Corporation Commission’s (OCC) oil and gas records database. There were no
records of wells on the subject property or in adjacent areas.
4.17 Dry Cleaner Databases
DEQ’s historic dry cleaner databases were searched for a radius of one mile around the
subject property (Ref. 21). Five historic dry cleaners were noted for Stilwell, Oklahoma. Pro
Cleaners was located 0.29 miles southeast of the subject property at 11 N. 1st Street,
Thomas’ Clean Cleaners (operated from 1963 to 1985) was located 0.33 miles southeast of
the subject property at 112 S. 2nd Street, and Drive in Cleaners (operated from 1965 to 1966)
is located 0.44 miles southeast of the subject property. The addresses of the following
historic dry cleaners was not descriptive enough to locate the property, they are: Nu-way
Cleaners (operated from 1946 to 1962) located on Main Street in Stilwell, Oklahoma and
Clean Cleaners (operated from 1941 to 1962) had a mailing address of Box 67 in Stilwell,
Oklahoma. To capture present day dry cleaners operating in the area, yellowpages.com
was searched (Ref. 22). One dry cleaner was listed within one mile of the subject property
(Modern Cleaners). Modern Cleaners is located 0.58 miles south of the subject property at
410 S. 2nd Street.
Phase I TBA 18 Former Stilwell Armory
Stilwell, Oklahoma
5.0 Site Reconnaissance and Interviews
5.1 Methodology and Limiting Conditions
A site reconnaissance of the subject property located at 421 W. Pine St., Stilwell, OK was
performed on May 3, 2012. Rachel Francks and Franziska Landes of the DEQ met the
caretaker of the subject property, Ronnie Trentham (City of Stilwell Mayor) at the subject
property. Trentham introduced Francks and Landes to the site and answered questions to
the best of his knowledge on the site. Trentham provided access to the building and
provided background information about the property to the best of his knowledge. All areas
of the building were observed noting any environmental conditions that might need
additional investigation. The entire outside area of the subject property was walked
through for observations that might need additional investigation as well.
5.2 General Site conditions
The former Stilwell Armory Property is composed of a brick building of approximately 11216
square feet that was built in 1954 and does not contain an indoor firing range (IFR). The
building is currently occupied and under renovation by the City of Stilwell. The city uses the
facility for storage and community activities. The property surrounding the building consists
of a residential area and an asphalt parking lot to the south; residential area to the east;
residential area to the south; and a public sports field to the west. The subject property is
in town and paved streets are located to the north, west, and south of the subject property.
The following are general site conditions that were evaluated on the property and adjacent
properties.
5.2.1 Aboveground Storage Tanks (ASTs)
There were no ASTs at the site, nor was there any indication that there had
been at any point.
5.2.2 Landfills and/or Dumping
There was no indication that any part of the property had been used as a landfill
at any point.
5.2.3 Impoundments
There was no standing water on the property. There is a ditch between the
road and the property to the west of the armory, and a large storm drainage
culvert to the south of the property. There was no water in the ditch at the
time of the site visit and the culvert had only a small amount of standing water.
Phase I TBA 19 Former Stilwell Armory
Stilwell, Oklahoma
Ronnie Trentham mentioned that improvements were planned for the culvert,
but did not know when they would be completed. It seems likely the water will
flow with the topographical gradient to the northwest.
5.2.4 Monitoring Wells
There were no wells noted during the site visit. The OWRB data viewer has no
record of wells being located on the property.
5.2.5 Disturbed and Stained Soils
There lot where vehicles were kept was overgrown with grass, so stained soils
would not be visible. The vegetation around the armory appeared to be in good
condition and did not appear distressed, except in an area of high traffic due to
the renovations that were occurring on the armory.
5.2.6 Seeps
No seeps of any kind were observed at the subject property.
5.2.7 Chemical Spills
No evidence of possible chemical spills was observed on the subject property.
5.2.8 Farm Waste
No farm waste was observed at the subject property.
5.2.9 Known Pesticide Misapplication
No known pesticide misapplications were detected during the site visit or during
the supportive research.
5.2.10 Discharges and Runoff from Adjacent Property Affecting the Site
Rainwater runs off to the west side of the subject property. No potential
pollutants were observed on the neighboring properties that may affect the
armory.
Phase I TBA 20 Former Stilwell Armory
Stilwell, Oklahoma
5.2.11 Petroleum Products and Oil and Natural Gas Exploration
No petroleum products or oil and natural gas exploration was observed during
the site visit.
5.2.12 Asbestos
Since many of the State armories were built before the 1970s, there is a high
potential of finding asbestos containing material (ACM) in the armory buildings.
The U.S. began banning the use of asbestos in most building products in the
1970s due to studies confirming the harmful health effects caused by exposure
to airborne asbestos. ACM may be found in the insulation wrapping of the
heating pipes and/or heaters, roofing materials, ceiling tiles, window putty,
mastic, and floor tiles. Floor tiles that are 9”x9” have been found to regularly
contain asbestos.
DEQ’s contractor has conducted an asbestos survey and survey and assessment
for lead in paint and settled dust in the armory. Asbestos was detected in
thermal pipe wrap and fittings, floor tiles, and transite soffits. Pipe with the
wrapping was noted in both bathrooms as well as the water heater closet, and
the drill floor. The pipe wrap is in fair condition and no areas of fraying were
noted.
5.2.13 Lead
Surveys for lead-based paint and lead dust throughout the building have been
conducted by a contractor for the DEQ. The reports indicate that lead based
paint is present in a few rooms on the walls, doors, windows, and roof/ceiling
trusses. There is not an IFR in this building, so any lead dust is most likely due to
deteriorated lead-based paint, or munitions stored in the building. Several
rooms showed lead levels above the HUD acceptable limits.
5.2.14 Transformers/PCB Equipment
There were two transformers observed to the west of the site, and one noted to
the east of the site, on an adjacent property. It is unknown if the transformers
contain PCBs, but they appeared to be in good condition.
5.3 External Observations
The exterior of the building appears to be in good condition. The armory is currently
undergoing renovations. There were no recognized issues with the exterior of the building.
Phase I TBA 21 Former Stilwell Armory
Stilwell, Oklahoma
5.4 Internal Observations
The building is currently unoccupied and was last used by the Oklahoma Army National
Guard to support the military mission. The one story building was constructed from brick in
1954. Before construction of the armory building, the land was owned by the City of Stilwell
and was occupied by a fair grounds. During the site visit on April 11, 2011, the building
appeared to be in good condition though there were signs of water damage along several
walls. No mold was noted during the site visit and Ronnie Trentham said that repairs had
been made to the roof to address the source of the damage. Photographs of the internal
view of the site can be found in Appendix B.
5.5 Interviews
Sheldon Miggleto (Treasurer – City of Stilwell) was listed as the point of contact for the
armory, due to a schedule conflict he was late to the meeting at the armory and so Ronnie
Trentham (Mayor – City of Stilwell) came in his place. Ronnie Trentham and Sheldon
Miggleto have limited knowledge of the site and were listed as the point of contact, because
of their positions with the City of Stilwell. Ronnie Trentham provided access to the building
for DEQ personnel, but had limited information regarding the history of the site. Therefore
interviews were not utilized in determining the operational history of the site.
Phase I TBA 22 Former Stilwell Armory
Stilwell, Oklahoma
6.0 Findings
Summarized below are the major findings from this Targeted Brownfield Assessment and DEQ’s
recommendations. The major findings of the highest environmental concern are presented first.
• The former Stilwell Armory was built in 1954. The land for the building was deeded by the City
of Stilwell to the Oklahoma Military for the State of Oklahoma, for benefit of the Oklahoma
National Guard. The armory is currently owned by the City of Stilwell and will be used for school
and community activities as well as a museum once cleanup activities are complete. A
Memorandum of Agreement (MOA) will be set in place between the OMD and the DEQ. Once
cleanup activities have occurred, a notice of remediation and easement will be filed in the Adair
County Courthouse.
 Four historic dry cleaners were found within a half mile of the site. One currently operating dry
cleaner was found within a mile of the site. It is unknown whether the dry cleaners are
upgradient of the site but it is possible based on surface topography. These are potential
environmental concerns (PEC).
• OCC records show the property formerly contained a 1,000 gallon UST that was closed in June of
1978 and finally removed August 22, 1995. Soil samples collected below the tank were below
detection limits for TPH. The former UST is considered a HREC.
• No National Priority List (NPL), delisted NPL sites, Resource Conservation and Recovery Act
(RCRA) non-corrective action sites (CORRACTS) treatment, storage, and disposal (TSD) listings,
Emergency Response Notification System (ERNS) list, Institutional Controls/Engineering
Controls, or State landfills and/or solid waste disposal sites were found on the subject property
or within the ASTM recommended search radii. No RCRA generators, Voluntary Cleanup (VCP)
sites, or Brownfield sites were found on the subject property. There were no RCRA generators
listed on the subject property or adjacent properties. There were no archived Comprehensive
Environmental Response, Compensation, and Liability Information System (CERCLIS) site listings.
The subject property is on the DEQ Site Cleanup Assistance Program (SCAP) list for cleanup of
lead and asbestos contamination.
• Four facilities with leaking underground storage tanks were found within a ½ mile radius and
potentially upgradient of the subject property.
• No transformers were noted on the site, though three are present on adjoining properties.
Fluorescent lighting ballasts are located throughout the building. The lighting ballasts are all in
good condition. The lighting ballasts may be a source of mercury.
Phase I TBA 23 Former Stilwell Armory
Stilwell, Oklahoma
7.0 Opinion and Recommendations
Due to the past use of the property and potential contamination found on the subject property, the
environmental professionals working on this site believe that cleanup of lead and asbestos will be
necessary.
8.0 Data Gaps
No tribal information was obtained for this assessment. No tax records, city directories, or zoning
records were reviewed for this report. No interviews of the operational history of the building were
conducted. However, this did not affect the ability of the DEQ to make a recommendation on the
subject property.
9.0 Conclusions
DEQ has performed a Phase I Environmental Site Assessment in conformance with the scope and
limitations of ASTM Practice E 1527-05 of the former Stilwell armory located at 421 W. Pine St.,
Stilwell, Oklahoma. Any exceptions to, or deletions from, this standard are described in Section 10.0
of this report. Recognized environmental conditions on this property include lead-based paint and
asbestos contamination throughout the building.
The information provided in this assessment is to assist the City of Stilwell in its revitalization
planning as well as meet the All Appropriate Inquiry requirement of the landowner liability
protections under the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA, better known as Superfund – Ref. 2), as provided in the Small Business Relief and
Brownfields Revitalization Act of 2002 (Public Law 107-118, Subtitle B – Ref. 3).
10.0 Additional Services
In addition to this Phase I Targeted Brownfield Assessment, DEQ has provided sampling analysis of
potential asbestos, lead-based paint, and lead dust sources including the remediation of the
building.
11.0 Deviations
The following deviations from ASTM Practice E 1527-05 occur in this Phase I Targeted Brownfield
Assessment. No tax records, city directories, or zoning records were reviewed for this report.
Phase I TBA 24 Former Stilwell Armory
Stilwell, Oklahoma
12.0 References
1. U.S. Environmental Protection Agency. (2008). Oklahoma Brownfields Assistance Agreement (No
#RP96681001-0). Unpublished Document. State of Oklahoma: Oklahoma City, Oklahoma.
2. U.S. Environmental Protection Agency. (1980). Comprehensive Environmental Response, Compensation,
and Liability Act. (Public Law 96-510). Washington, DC: U.S. Government Printing Office.
3. U.S. Environmental Protection Agency. (2002). Small Business Liability Relief and Brownfields Revitalization
Act. (Public Law 107-118, Subtitle B). Washington, DC: U.S. Government Printing Office
4. ASTM International. (2005). Water and Environmental Technology: Phase I Environmental Site Assessment
E 1527 – 05. Baltimore, Maryland.
5. Environmental Protection Agency. EPA National Priority List. Last accessed March 19, 2013.
http://www.epa.gov/superfund/sites/npl/status.htm.
6. Environmental Protection Agency. EPA Deleted National Priority List. Last accessed March 19, 2013.
http://www.epa.gov/superfund/sites/query/queryhtm/npldel.htm
7. Environmental Protection Agency. CERCLIS current and archived sites. Last accessed March 19, 2013.
http://cfpub.epa.gov/supercpad/cursites/srchsites.cfm.
8. Environmental Protection Agency. RCRA database. Last accessed March 19, 2013. RCRA database.
http://www.epa.gov/enviro/html/rcris/rcris_query_java.html.
9. National Response Center. Emergency Response Notification System. Last accessed March 19, 2013.
http://www.nrc.uscg.mil/foia.html.
10. Oklahoma Department of Environmental Quality. State Landfill site list. Last accessed March 22, 2013.
http://www.deq.state.ok.us/LpDnew/swindex.html.
11. Oklahoma Department of Environmental Quality. DEQ ArcGIS Viewer. Last accessed March 22, 2013.
http://gis.deq.ok.gov/flexviewer/
12. Federal Emergency Management Association (FEMA). FEMA Issued Flood Maps. Last accessed March 22,
2013.
http://www.msc.fema.gov/webapp/wcs/stores/servlet/CategoryDisplay?catalogId=10001&storeId=10001
&categoryId=12001&langId=-1&userType=G&type=1&future=false
13. Oklahoma Department of Environmental Quality. RCRA NOTIFIERS sorted by county and then city. Last
accessed March 19, 2013. http://www.deq.state.ok.us/LPDnew/HW/Notifiers/notifiersbycountycity.pdf.
14. United States Department of Agriculture, Natural Resources Conservation Service. (n.d.). Web soil survey.
Last accessed March 22, 2013. http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx
15. Oklahoma Water Resources Board. OWRB Custom Map Viewer-Data Driven Map Viewers. Last accessed
March 21, 2013. http://www.owrb.ok.gov/maps/server/wims.php.
16. Oklahoma Department of Environmental Quality. Oklahoma Brownfield’s Institutional Control Database.
Last accessed March 21, 2013.
http://www.deq.state.ok.us/lpdnew/Brownfields/IC%20Documents/IC%20Database%20edit.html
17. Oklahoma Department of Environmental Quality. Oklahoma Brownfield’s Public Record. Last accessed
March 22, 2013. http://www.deq.state.ok.us/lpdnew/Brownfields/PublicRecordBrownfields.pdf
Phase I TBA 25 Former Stilwell Armory
Stilwell, Oklahoma
18. Digital Sanborn Maps 1867-1970. Stilwell, Adair County, OK. (1946). Last Accessed March 22, 2013.
http://sanborn.umi.com/
19. Johnson, Kenneth, & Luza, Kenneth. Oklahoma Geological Survey, (2008). Earth sciences and mineral
resources of Oklahoma (Educational Publication No. 9). Norman, OK: University of Oklahoma Printing
Services.
20. Rachel Francks, Oklahoma Department of Environmental Quality, interview notes with Stilwell Mayor,
Ronnie Trentham and City Clerk, May 3, 2012, Stilwell Armory.
21. Oklahoma Department of Environmental Quality. Historic Dry Cleaner Databases. DEQ Archives. Last
viewed March 22, 2013.
22. YP Intellectual Property LLC. http://www.yellowpages.com Last viewed March 22, 2013.